Yeah. Those FE cards especially have fairly mediocre cooling, and may even have trouble maintaining a stock boost clock in some games with how fast they can heat up.
My point was not to go and get a FE card, but that spending $50 extra for a factory overclock isn't a very good deal, especially when you can just overclock the card, yourself. A 200 MHz overclock is only an 11% speed increase, which although it's significant, won't make or break much of anything.
Eventually, the cheaper GTX 1080s will have to be in stock again, anyway. The reason why some of the more expensive $700 variants are still in stock is because other people are also waiting.
